A number of European countries have been struggling with the dilemmas posed by the Muslim headscarf, which throws up a variety of difficult issues relating to tolerance and equality.

Many Muslim women believe it is their right to wear the scarf

France is introducing a ban on the wearing of veils in schools, while in Germany, two states have proposed legislation which would also bar the scarf from educational institutions.

In both countries it is argued that the covering of the head is a symbol of women's oppression which has no place in a democratic society - and certainly not in a school.

Some female Muslims, feminists note, are forced into wearing the scarves by men - fathers, brothers, boyfriends and husbands.

But there are undeniably Muslim women and girls who of their own accord believe they should be covered up. They declare they are suffering discrimination at the hands of the state and being denied their right to freedom of religion.

Equality versus tolerance

For both countries, efforts to prevent the headscarf appearing in civic spaces have raised serious questions about religious tolerance, and fuelled the ongoing row about the relative benefits of assimilation as opposed to multi-culturalism in an age of immigration.

Those hostile to the headscarf on the grounds of their objection to the nature of the Muslim faith - which is viewed by some as profoundly intolerant - find themselves in the awkward position of seeking themselves to stamp out the expression of a religion in the name of tolerance.

But those who have fought vigorously for the equality of the sexes are unhappy about the sanctioning of a symbol which appears to contradict what they have long campaigned for.

"If we allow women to wear headscarves in state schools, then the republic and French democracy have made clear their religious tolerance but they have given up on any equality of the sexes in our country,"
says French philosopher Elisabeth Badinter

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But these concerns about female oppression within the Islamic faith also have to be squared with the fact that a number of Muslim women also want to wear the veil.

In France, campaigns to stop the state cracking down on the wearing of the headscarf are often run by young Muslim women confident of their right to fulfil their potential and their right to express their religion.

In Germany, 31-year-old teacher Fereshta Ludin went to the country's highest court to argue that a school was wrong to exclude her for wearing the scarf.

An educated young woman of middle-class parents, she had no qualms about her right to both pursue a career and to wear the veil.

"I see my religion as a fundamental part of my identity," she declared.

But while many women clearly do see the wearing of the scarf as a personal identity issue, their insistence upon it is raising issues about the political identity and the authority of the state.

In France, secularity has been enshrined in the constitution since 1905, meaning that all religious effects are, in principle, to be kept out of the classroom.

But the country has not always been so keen to assert a ban on headscarves in schools. In 1989, the then left-wing government declared that the wearing of scarves was not necessarily incompatible with France being a secular state as long as they were not ostentatious.

The decision on whether to allow pupils to wear them or not has up to now been left up to the discretion of headteachers.

But the new legislation has been applauded by a number of women's rights activists, but has also left the government open to allegations of racism, and to the charge that it is seeking to woo the large numbers of voters who opted for the far-right, anti-immigrant leader Jean-Marie Le Pen in last year's presidential election.

Other critics worry that the law will simply push Muslim girls out of the state system, jeopardising integration.